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Data Protection Policy

GROW PUBLIC RELATIONS PTE. LTD.

PERSONAL DATA PROTECTION POLICY

GROW PUBLIC RELATIONS PTE. LTD. (“Company”, “we”, “us” or “our”) is committed to the protection of your personal data which you have entrusted to us.

This Policy (“Policy”) explains how the Company collects, uses, discloses, and protects your personal data.

Please note that this Policy may be amended or updated from time to time without notice to reflect the change/s in the applicable personal data protection laws.

YOUR CONSENT

1. By interacting with us and/or our authorised agents, vendors and the like and visiting our website and submitting any personal data and/or information (“collectively as information”) to us, you agree and consent to the Company, including its related companies, as well as their respective representatives and/or agents to collect, use, disclose your information to our authorised service providers and relevant third parties for the purposes and in the manner set forth herein.

2. You are also deemed to have given your consent for the collection, use, and disclosure of your personal data when it is reasonable for you to have provided the personal data to us in the circumstances allowed under the law.

PERSONAL DATA DEFINED

3. In this Policy, “personal data” means data, whether true or not, about an individual who can be identified —

(a) from that data; or

(b) from that data and other information to which the organisation has or is likely to have access to and includes but is not limited to:

  1. i. Identity data such as your name, gender, and date of birth;
  2. ii. Contact information such as a delivery address, telephone numbers, and email address;
  3. iii. Account data such as bank account and payment information (e.g., name of cardholder, card number, billing address, expiry date) and the like;
  4. iv. Network data such as your internet protocol address, cookies, web browser type, and version, operating system, the domain name of your internet provider, location, and device identifier and/or any information generated from any computer system/s;
  5. v. Health-related and biometric data, and all personal information necessary for the provision of our services to you and necessary for your experience in our stores; and/or
  6. vi. Any other information relating to any individual/s which you have provided to us in any form/s which you may have submitted to us, or obtained through any form of interaction with you whether through any electronic system or with you in person.

 

COLLECTION OF YOUR PERSONAL DATA

4. Generally, the Company collects your personal data when:

  1. (a) You visit our website or participate in our promotions, contests, campaigns, customer surveys or any other marketing initiatives;
  2. (b) You accept our cookies on your device/s;
  3. (c) You interact with us on our social media platform/s;
  4. (d) You interact with our staff or other representatives, through face-to-face meetings, telephone calls, letters, emails or fill in our webforms;
  5. (e) You subscribe to our publication/s or marketing collaterals;
  6. (f) You enquire about our products or services in any form;
  7. (g) Your authorised representative submits your personal data to us for any purpose authorised by you; and/or
  8. (h) You voluntarily submit your personal data to us for any other reason.

 

USE AND DISCLOSURE OF YOUR PERSONAL DATA

5. The personal data which we have collected from you may be used by us and/or shared with or transferred to a third party such as our related companies and our authorised service providers for which purpose may include but is not limited to the following:

  1. (a) To facilitate your use of our website including the identification of visitors;
  2. (b) To respond to your queries, complaint/s, feedback, claim/s, or any update/s;
  3. (c) To deliver any services you have purchased through our website;
  4. (d) To administer our promotion/s, contest/s, campaign/s, customer survey/s or any other initiative/s;
  5. (e) To ascertain or to investigate any fraud, carry out an audit or any other investigation/s as required under the law;
  6. (f) To comply with the legal requirements under any relevant law; and/or
  7. (g) To fulfil any other business requirement/s.

 

THIRD PARTY PERSONAL DATA

6. To the fullest extent permitted under the law, the Company cannot be responsible for any consequence/s arising from your use of any third-party’s link on our website, and any such liability is expressly disclaimed and excluded.

7. If you provide us with any personal data relating to a third-party including but not limited to information of your spouse, children, parents, employees, you represent to us that you have obtained the consent of the third-party in the provision of that personal data.

8. You may unsubscribe from receiving any marketing information from us at any time by using the unsubscribed method/s as described in any marketing material/s provided.

TRANSFER OF YOUR PERSONAL DATA

9. If you are in Singapore, we may transfer your personal data outside of Singapore for any of the purposes set out as in the above.

10.The Company will not transfer any of your personal data outside of Singapore unless the transfer conforms with the requirements under the law.

SECURITY OF YOUR PERSONAL DATA

11.We will protect your personal data by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risk/s.

12.Despite such reasonable efforts, please note that it is the nature of the Internet, that any transmission and any method of electronic storage is inherently insecure, and the Company cannot warrant the security of the information which you have provided to us.

13.We assume no liability for disclosure of your personal data due to errors in transmission, unauthorised third-party access, or other causes beyond our control.

ACCESSING & CORRECTING YOUR PERSONAL DATA

14.You should ensure that all personal data submitted to us is true, accurate and complete. Failure on your part to do so may result in our inability to provide you with the goods and services you have requested.

15.You may request information about how your personal data is managed and may correct and/or update any personal data submitted to us you deem erroneous.

16.We reserve the right to charge a reasonable administrative fee for retrieving your records/s and we will inform you of the fee before processing your request.

17.We will respond to your request within 30 days of the date of your request.

WITHDRAWAL OF YOUR CONSENT

18.You may communicate the withdrawal of your consent to the collection, use or disclosure of your personal data by submitting your request in writing to our Data Protection Officer.

RETENTION OF YOUR PERSONAL DATA

19.We will only retain your personal data for as long as it is necessary for any legal or business purpose.

NOTIFICATION OF DATA BREACHES

20. When the Company is made aware of a breach of personal data, the Company will assess whether the breach is a notifiable breach under the Act.

21.A notifiable data breach is one where (a) it results in or is likely to result in, significant harm to the affected individual(s), or (b) is, or is likely to be, of a significant scale.

22.The Company will inform the relevant authorities if the breach is a notifiable one, and in consultation with the authorities, may inform you of the breach and provide the necessary information concerning the breach through the Company’s website or any other means.

23.Where in compliance with any lawful order of any regulatory agency within Singapore, the Company may not inform you of any data breach incidents that may occur in the Company, its related entities, agents suppliers and the like.

YOUR DATA AND COMPANY’S DATA INTERMEDIARY

24.A Company’s data intermediary processing any personal data of the Company shall without undue delay, notify the Company if the data intermediary is aware of any breach of personal data within the intermediary or a related entity of the intermediary.

GOVERNING LAW

25.This Policy and your use of the Company’s services and website shall be governed in all respects by the laws of Singapore, and under the exclusive jurisdiction of the courts of Singapore.

DATA PROTECTION OFFICER (“DPO”) CONTACT DETAILS

26.Please contact or write to our Data Protection Officer if you have any request or question at: [email protected]

27.The DPO will acknowledge receipt of your query or request within 3 working days and we endeavour to respond to your query or request within 30 days from the date of submission. As a matter of policy, we do not attend or respond to an anonymous and/or abusive query or request.